The defendant is charged [in count __]
with the alteration of a firearm identification mark. The statute defining this
offense reads in pertinent part as follows:

no person shall (remove / deface /
alter / obliterate) the name of any maker or model or any maker's number or
other mark of identification on any firearm.

For you to find the defendant guilty
of this charge, the state must prove beyond a reasonable doubt that the
defendant (removed / defaced / altered / obliterated) the name of any maker or
model or any maker's number or other mark of identification on a firearm.

A "firearm"
is any sawed-off shotgun, machine gun, rifle, shotgun, pistol, revolver or other
weapon, whether loaded or unloaded, from which a shot may be discharged. For
purposes of this offense, you must find that the firearm was operable.1

[<Insert if applicable:>

The statute defining this offense
provides that if you find that the defendant was in possession of or owned a
firearm on which the maker's name, number, model or other identification mark
has been (removed / defaced / altered / obliterated), then you may find, but are
not required to, that it was the defendant who (removed / defaced / altered /
obliterated) the identification mark, number, model or name of the firearm.This inference is not a necessary
one, but it is an inference you may draw if you find it is reasonable and
logical and in accordance with my instructions on circumstantial evidence.2

The defendant need not be the owner of
the firearm to have been in possession of it. "Possession"
means either actual possession or constructive possession. Actual possession
means actual physical possession, such as having the object on one's person.
Constructive possession means having the object in a place under one's dominion
and control.

Possession also requires that the
defendant knew that (he/she) was in possession of the firearm. That is, that
(he/she) was aware that (he/she) was in possession of it and was aware of its
nature. The state must prove beyond a reasonable doubt that the defendant knew
that (he/she) was in possession of the firearm. <See
Knowledge, Instruction 2.3-3.>

<If some form of constructive
possession is alleged, see
Possession, Instruction 2.11-1.>3]

Conclusion

In summary, the state must prove
beyond a reasonable doubt that the defendant (removed / defaced / altered /
obliterated) the name of any maker or model or any maker's number or other mark
of identification on a firearm.

If you unanimously find that the state
has proved beyond a reasonable doubt each of the elements of the crime of
altering a firearm identification mark, then you shall find the defendant
guilty. On the other hand, if you unanimously find that the state has failed to
prove beyond a reasonable doubt any of the elements, you shall then find the
defendant not guilty.
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1
This statute specifically incorporates the definition of "firearm" as found in
General Statutes § 53a-3 (19), which requires that the firearm be operable.